Does anyone include OFAC testing in their ACH audit? I have completed our ACH audit, but it just occurred to me that I didn't mention anything regarding us checking originator files with OFAC. We will hit this on our BSA combined audit, but does anyone include this in both areas?

As long as it is tested under one of the audits (at an appropriate interval) you should be fine. No need to test under multiple audits unless you feel the risk justifies it.

I agree with the prior post, but I will add that you definitely need to make sure they have included reviewing OFAC information as part of their ACH procedures.

BSA / OFAC / CIP / etc. are definitely hot topics with the examiners (Fed) and they got us for lack of OFAC checking in the ACH area...

That is what I am afraid of. I have added the comment to the ACH audit just to make sure I cover my basis...maybe with any luck they will have it fixed by the time we get the BSA,etc. one done.

We certainly recommend making sure all of our clients have it in their procedures.

I was talking about those files that we send out to other banks as the originating depository fin. institution. Our agreements with originators do state they will follow US Laws, but not sure they have been told specifically to check the names against the OFAC listing. I do believe it would fall back to the bank, not the company we are originating for, if one went through that was ultimately on the OFAC listing.

No, we don't check every check that goes through, but we do check every customer as well as every wire and I think you need to have procedures for ACH as well.

For what it's worth, here are the NACHA guidelines.